DCM Legal Ltd Claim Form-Civil National Business Centre

abz_anony

Sorry 1 last question:
On the topic of signature I used word doc for my defence which was converted to PDF file and my signature is my typed name reads as in the example below, is this sufficient

Signature: Joe Bloggs
Date: 3/3/2025

Umkomaas

abz_anony said:

Keith, Coupan-Mad and other contributors and guiders

Much indebted to you. Everything is prepared and have just emailed CNBC, have to go work at 8 am so not sure if would have got time before 3 pm to make any adjustment-- one last thing to be doubly sure,

Claimant in question is Secure Parking Solutions Ltd represented by DCB Legal. I used Shahib_02 defence below but notice that his Claimant was CEL represented by DCB Legal. 

Can you please advise if this is OK.
  

The facts known to the Defendant:

2.     The facts in this defence come from the Defendant's own knowledge and honest belief.  Conversely, the Claimant sets out a cut-and-paste incoherent and sparse statement of case. The POC appear to be in breach of CPR 16.4, 16PD3 and 16PD7, and fail to "state all facts necessary for the purpose of formulating a complete cause of action". The Defendant is unable, on the basis of the POC, to understand with certainty what case, allegation(s) and what heads of cost are being pursued, making it difficult to respond. However, the vehicle is recognised and it is admitted that the Defendant was the registered keeper and driver at the time.

3.     Referring to the POC: paragraph 1 is denied. The Defendant is not indebted to the Claimant. Paragraph 2 is denied. No PCN was issued on 24/06/2021.  Whilst the Defendant is the registered keeper and driver , paragraphs 3 and 4 are denied. The Defendant is not liable and has seen no evidence of a breach of prominent terms.  The quantum is hugely exaggerated (no PCN can be £170 on private land) and there were no damages incurred whatsoever. The Claimant is put to strict proof of all of their allegations.

3.1 The Defendant had to attend a life-threatening medical emergency at the given location for a very short duration. The Defendant has informed the Claimant about this situation but the Parking Charge has not been cancelled,

Seems okay to me. Your Witness Statement (in due course) will need to expand on the medical issue. 

Umkomaas

abz_anony said:

Sorry 1 last question:
On the topic of signature I used word doc for my defence which was converted to PDF file and my signature is my typed name reads as in the example below, is this sufficient

Signature: Joe Bloggs
Date: 3/3/2025

That's fine, or you could use a 'fancy' font that looks a bit like handwriting. Up to you. 

Coupon-mad

Was no payment (at all) made for parking? Why? What happened?

abz_anony

Coupon-mad said:

Was no payment (at all) made for parking? Why? What happened?

Apologies for the late reply. Too much personal stuff and work related stresses to deal with and haven't been able to attend to the site.
Essentially was travelling with a child passenger who has lots of respiratory ailments, child began to choke, pulled up emergency into safe location from one of the busiest main roads in the city into a side passage road adjacent to the main road. Attended to child for about 20 minutes and then drove off.
To be honest didn't have time to look at sigs etc. However have travelled on this busy main  road many many times. No clear signage about private car park spaces on the adjacent attached road and also the adjoining main busy road has free council car park spaces which are within 5 metres of the private car park spaces and parallel with each other. I will try and and upload some images later.

abz_anony

Have received DQ. Deadline for posting is 24th April (tomorrow). Have a few questions baout certain sections please:

C- Track: Do you agree the small claims track is appropriate for this case?
I think answer should be YES

F- Hearing venue: At which County Court hearing centre would you prefer the small claims hearing to take place and why?

Live in Birmingham and so would prefer my local County Court.
Do I just put down Birmingham County Court or some additional description to to this aswell?

I have to serve DQ to Civil National Business Centre and serve copies to all other parties.

The claimant is Secure Parking Solutions Ltd and company acting on their behalf is DCB Legal LTd, Direct House, Greenwood Drive, Runcorn

Do I serve DQ copies to the Secure Parking Solutions Ltd or DCN Legal Ltd or both?

I suspect it is going to be DCB Legal Ltd in which case I have to try and locate their email.

Does anyone know how I can get their email please?

Many Thanks

Final question: When will I have to prepare Witness Statement with evidences etc. Must say I thought that will be with DQ but I think I'm wrong. Sorry.

Umkomaas

All above explained in the Template Defence Announcement (near the top of the forum thread list) - Step 8 of 'THE FIRST 12 STEPS'.  Please read through that.